SEC Sides with Shareholders: Climate Risk and Its Impact on the Cost of Home Insurance
A Conversation Between Arthur Kohn, Chair, Editorial Committee, Capitalism Today and Danielle Fugere, President & Chief Counsel, As You Sow / September 1, 2025
One of the longstanding features of U.S. corporate governance is that small shareholders have the ability to ask all of a company’s shareholders to vote on certain proposals at the company’s annual shareholders meeting. Small shareholders of US public companies can require companies to describe such proposals, and advocate for them, on a company’s annual proxy statement for the election of directors.
These rights are required by U.S. securities laws, rather than state corporate law. There are complex and contentious implementation rules, and there has been a decades-long tug-of-war between companies and shareholders, including corporate gadflies, about the technicalities. Generally, the U.S. Securities and Exchange Commission (SEC) has mediated those debates, under what’s referred to as the “Rule 14a-8 process”.
In the last annual meeting season, the environmental and social advocacy non-profit As You Sow won a significant victory when it convinced the SEC to include a proposal in the proxy statement of the prominent US property insurer The Travelers Companies Inc.’s (Travelers) annual meeting of shareholders relating to climate change.
Specifically, the proposal asked shareholders to approve a resolution that Travelers provide, in its existing climate reporting, the expected impact of climate-related pricing and coverage decisions on the sustainability of its homeowners' insurance customer base under a range of climate scenarios in the near-, medium- and long-terms. That proposal was approved by about 12% of the company’s shareholders voting at the meeting.
Prior to the annual meeting I spoke to Danielle Fugere, As You Sow’s President and Chief Counsel, about the resolution and climate change. The following is a lightly edited transcript of that conversation.
Arthur Kohn: Thank you for agreeing to talk. Can I ask to describe what you’re asking of Travelers and what you brought to the SEC for its review?
Danielle Fugere: Very briefly, we have been working with various insurers since 2022. Initially we asked insurers to issue a report addressing how they were going to measure, disclose and reduce the greenhouse gas emissions associated with their underwriting and insuring activities and to do so in alignment with the Paris Agreement’s 1.5° goal. It's part and parcel of investors’ concerns that every company needs to align itself with the Paris Agreement and be heading toward 1.5° emissions reduction because truly that's the only way we're going to address this growing problem.
Specifically, since 2022 have been engaging with insurers, including Travelers, and asking about the impact of the insurers’ continuing to invest in the very activities that are causing the climate problem. If not addressed, we move into a vicious circle. We’ve said don't stop investing in those activities, but you, like everybody else, need to transition in terms of what you're adding to the climate scenarios and to climate risk.
Over the past few years, it has become very clear to us that as climate change increases, it is becoming more difficult for insurers to be profitable. Catastrophe losses have increased dramatically. For just Travelers alone, which is one of California's largest insurers, catastrophe losses increased from 1.85 billion in 2021 to 2.99 billion in 2023. That's pretty significant.
Now, Travelers is still making money because it's been able to increase its prices, but what we're seeing is that prices are so high that people are increasingly unable to afford insurance. We're also seeing homeowners that own their home choosing not to buy insurance because it's so expensive or because they don't believe that they'll be covered when the time comes.
As that is increasingly the case insurers need to leave markets because they become unprofitable. You're starting to see that in more areas in California and Florida and really across the nation. One thing that we are noting that may not as be as evident to everybody is that this isn't just those markets like Florida and California where we're starting to see increased catastrophe losses. It's across the nation. We're seeing losses and droughts. We're seeing convection storms, you know, normal storms becoming more frequent and more dangerous when you've got hail the size of snowballs, that's very damaging to cars and homes. That raises the cost of insurance even across the Midwest.
This is not a problem that's going away on its own and it's not a problem that governments can solve. What we're seeing are a lot of stopgap measures. We're seeing fair plans, but in the end those plans mean reduced coverage at a higher prices.
As climate change continues to increase, we have a crisis on our hands. So that's what we were looking at and saying, “huh, what is the market for private insurance when you have to keep increasing prices and or moving out of large areas that were previously insurable?” What does that look like?
So we asked Travelers to issue a report on the expected impact of climate related pricing and coverage decisions on the sustainability of its homeowners’ insurance customer base under a range of climate scenarios. Tell us what you're thinking. Do you believe that your homeowners’ insurance market will shrink? Will you remain profitable? How will you remain profitable? This in essence is the information that investors are seeking from the company this year.
AK: That’s very helpful. Just a couple clarifying points from me. You talked about having engaged with Travelers since 2022 and I am interested in whether Travelers made any effort to talk to you about this proposal rather than including it in the proxy and to see what they could do to address your concerns outside of the 14A-8 process. Has there been a history on this with Travelers that you would be able to talk to us to about?
DF: We have engaged with Travelers every year. The company meets with us every year. Travelers has sort of has drawn the line on measuring and disclosing its emissions associated with its insuring and underwriting activities. We're really looking to say, OK, if you are investing in high carbon companies, if you're insuring new oil and gas projects, for example, tell us what the emissions are associated with that. So it's very similar to what banks have done and then once you understand what those emissions are, then we wanted them to disclose those and set targets. So that is something they've been unwilling to do for a variety of reasons. But in 2022 we did get a 55.8% vote supportive of that proposal. What Travelers has done is it has disclosed some of its investment information. That has been helpful and but it's unwilling to set targets.
And then this year this new request, we did discuss it, but essentially Travelers believes that it has the issue handled and and shareholders don't need additional information, to summarize my take-away.
Arthur: Very helpful. Drilling down a little bit into an issue you just touched on, Travelers and other insurance companies are concerned about extreme weather patterns, rate increases and underwriting standards with a specific overall concern about the net negative impact on the long-term viability of insurance product lines and business models. Can you tell is in a little more detail how your engagement with the insurance sector and how these resolutions with companies like Allstate, Berkshire Hathaway, and The Hartford, actually affect climate risk and its impact on pricing of policies and subsequently on shareholder value?
Danielle: I think what we are looking at in particular is that we again in 2025 are facing what's predicted as an above average hurricane season and above average wildfire season. And we're also seeing that tariffs will add costs that insurance companies will have to deal with and that will be above and beyond inflation. And we hear from some insurance companies, I think Travelers made this argument in it's proxy, is that most of the increased catastrophe losses are not due to climate change. They're due to increase inflation or people coming to the risk or coming to the coasts. So more and more people living in harm's way.
Arthur: And there are larger home sizes, right?
Danielle: But none of that is separate from climate change. Those factors simply exacerbate the problem. If more people are coming to areas that are hard hit and they're building more expensive homes, then they're seeking insurance for those things. The insurance companies are paying the higher costs associated with all of those things.
And then as you have catastrophes, obviously materials costs are very expensive in those areas because there's a lot of building going on and there's a shortage of labor which increases costs associated with that catastrophe. I would point out that catastrophe insurance prices have increased 40% more over the last decade than inflation itself.
Arthur: That's an interesting and important statistic.
Danielle: This is above and beyond mere inflation. We have catastrophe losses that have to be covered. And if these areas aren't profitable, insurers move out, but they have a business to run. All of that raises concern for us.
We believe that if insurers were not contributing to the harm, that could decrease harm. We’re asking the insurers the same thing we’re asking every other company, to align with the 1.5° goal. If everybody does that and asks their suppliers to do so across the board, we have a reduction in risk. We believe that these proposals are very much designed to reduce risk.
And they're designed to give additional information to shareholders. Is it more appropriate to invest in Travelers? Let's hear what your plan is because from looking on the outside, there's insufficient information for investors to understand what the risks truly are.
Arthur: Could I ask you to focus in on the time frame issue. You've touched on the point, but I think it'd be helpful to just be a little a little more explicit on the time frame issue. The climate accord targets are - I don't know if you'd call them medium-term or long-term targets, but you've also focused on stuff that's happening right now. Your proposal specifically mentioned short-, medium- and long-term risks. Are you equally worried about the different time frames, or how do you think about that issue?
Danielle: Well, that's such an important question because I think when people think about climate change, they think about long-term risk, right? Oh, it's something that will happen in the future. We'll just keep doing what we're doing today because it's making us money and ignore the future because it's . . . in the future.
What we see now, this is really what we call the first financial crisis associated with climate change. And it's a big one. It's happening today. It's not tomorrow. It's not mid-term or long-term issue. It's today. It's a crisis for the insurance companies. It's a crisis for homeowners.
If in fact we can't insure people's homes, that means that prices on those homes fall. And we're starting to see a massive decline in the price of homes, partially because of the inability to get insurance. If you don't have insurance, if you can't get insurance on a property, you can't sell that home to anybody except for cash. If you need a mortgage, you won't get a mortgage until you have insurance. We see a crisis. We have a crisis now. But that crisis could get much bigger. This could look like the 2008 recession associated with the value of homes because we're starting to see a crash.
Arthur: That's another interesting point. Perhaps there is a little paradox here, which is that if the dynamics of the market result in reduced value, does that mean that the insurance industry's exposure is going down? Does that help solve the risk problem for the insurance companies?
Danielle: So now we’re right in the dynamics. I would think it should or could ameliorate it in some sense, but at a very high cost to society and homeowners and people. I think that the costs will dominate. The extent of damage across the nation will far exceed what minor savings the insurers recoup. That will take some time to play out. What is happening now is the inability to get insurance. That's happening today. That's an impact on the mortgage market today.
As we start to see home prices fall, that harms the localities who are dependent on the real estate taxes. And then when the next catastrophe comes and insurance doesn't cover the costs, then a lot of times a lot of that falls on the local governments, which now will be cash strapped. And to add to the quagmire, we're starting to see the federal government withdraw Federal Emergency Management Agency (FEMA) payments. And the National Oceanic and Atmospheric Administration (NOAA), the agency that gathers data on which insurers rely, is starting to evaporate. They're no longer funding that data.
Where are the gaps going to be? How is that going to impact insurance companies? How will they deal with it? Because they aren't out there collecting the weather data, nor can they make their own predictions. Brewing catastrophe is get going to be far worse if insurance companies can't make the right decisions because of a lack of data. We’ll have an even worse problem.
I don't know that the people have internalized that because how do you price it accurately? How do you decide where you have to withdraw if you don't have accurate predictions and accurate data? You can't look backwards for information about future climate risk. We just don't have that information and it won't be the same as last year. The money and data evaporating is an interesting metaphor for climate change.
Arthur: While we're talking about the federal government, the push to increase use of fossil fuels at the federal level just makes these issues more important, right? In many ways investors are also asking companies, insurance companies and every other company that will be impacted by climate change, to actually go talk to the federal government because of the risks. You use the term “catastrophic”.
Danielle: I don't want to use it loosely, but all markers will go in the wrong direction.
Arthur: Do you see this as a political issue?
Danielle: It's not political. It is a fact. It's just a fact that this administration is withdrawing money to gather data that will implicate and harm the insurance market and its ability to predict risk and its ability to decide where to insure. That's just a fact. If we increased use of fossil fuels, that will speed the rate at which we have catastrophic climate impacts. All of those things are simply facts that that we have to deal with because those are the current realities. NOAA has already had its budget cut substantially. We have to deal with that. And you can't ignore the facts.
Arthur: Before we leave this train of thought I want to see if I can encourage you to tease out one more point, which is the following. On the one hand, we have to deal with the profitability of the insurance industry, the investor's perspective on putting their money at risk as you say in your proposal. On the other hand, we have societal implications, which you've also talked about when you put in a 14a-8 proposal. I understand, I think, why the two issues go hand-in-hand, but I think they’re in an important way separate issues.
I'm interested in how or if you would distinguish them. There's a long history, which I don't have to tell you about, of Rule 14a-8 proposals focused on social issues and Rule 14a-8 proposals focused on investor concerns. Do you think about those separately at all, and how do you think about how they go together?
Danielle: I think a company doesn't operate in a vacuum. It operates in a society. It operates with employees; it operates with homeowners. The term of art “ESG” has become politicized. I think wrongly so. What investors have said, as I said above, is we got 55.8% support on our climate proposal in 2022. Why? Because climate risk is real. Investors understand that and they have an important financial interest in addressing this before it becomes a problem.
We have the opportunity to invest resources. We can invest in high carbon companies, which is quite costly because you've got to drill and you've got to make pipes and you've got to put you a tremendous amount of resources into creating that type of energy. You could take those same resources and put them into cleaner energy and that reduces risk and creates an opportunity to continue business as usual with the new energy sources.
If the costs of renewable and clean energy are lower over time, that means that people have more money in their pockets to spend, which means that there's a better economy.
When you look to who are the investors, the largest investors are asset owners like pension funds. Their job is to protect their beneficiaries over time and ensure that that they are getting a good rate of return so that they can actually pay pensions to all the firefighters and teachers, so people who have worked hard all their lives are able to retire and their retirement is sound.
Now, as we look to the science around climate change, what we see is that it's costing hundreds of billions of dollars now in catastrophic costs. And those costs will increase. And what the predictions are is that GDP will decline by trillions of dollars by 2050. But when you talk about the time horizon, it's not just it all happens in 2050. Every single year your impacts and costs of climate change are increasing, which is decreasing often returns in the market.
Asset owners have are concerned about what we call systemic risk. When the risks become high, you can't necessarily predict what companies you want to win, if you're a pension fund, you diversify. You end up holding the entire market and all of that now is increasingly at risk. I would say all of these environmental risks are social risks and investment risks.
Social and investment risks are linked. The way to address climate change also involves both social- and investment-oriented steps. When you talk about social issues, you might be talking about diversity in the workplace. Studies have shown that a more diverse board, more diverse employees are actually financially increase profit and increase.
There's a range of markers illustrating the point: companies will be more valuable over time if they have a diverse workforce and they have a diverse board. We’re beyond the time where companies can simply externalize costs without having those costs impact the wider market or individual companies and in different ways according to what they do and what they sell. We believe that's why investors focus on these things, not because of politics, but because we live in a modern society. We've got educated employees. They want to work for companies that are doing the right thing, that are improving the value of the world and not decreasing it.
We've got pension funds that care about ensuring that they can make money over time for the people who are in the market now. Those people may be starting to put money into 401K plans. They will be invested for 20 or 30 years before they can even get their retirement dollars out. What does that world look like 20 or 30 years from now? Probably worse than what it looks like today if we don't address the problem.
Our position is very much that climate risk is financial risk. We have the opportunity and we're smart enough to solve this problem. We just have to have the will to do it, so that all of us will be better off.
Arthur: Let’s move on. The Travelers claims that investors are attempting to micromanage climate change policy without subject matter expertise. What are the broader implications of this ruling on company performance in the context of profitability impact and policies on nonrenewals and rate increases? Given that their customer base is shrinking due to increases in claims experience, what should investors know about placing their capital at risk?
Danielle: I don't think investors claim to be, you know, science experts. But what we do know, and it's quite obvious at this point and it has been for decades, that climate change has extreme risks. As investors, we want Travelers to provide information because truly it is better equipped to analyze risk than investors are.
We would look to the company to say we as investors can see the market fundamentals changing. We see prices getting higher. We see homeowners not being able to afford that insurance. We see coverage declining and States having to take over markets because private insurers like Travelers can't make a profit in those markets. It's fair enough for investors to say “huh, your market doesn't look as valuable as it did five years ago. Tell us what it looks like in various scenarios of what the future might hold because you indeed have the expertise, and you've got better data than we do. We want to know if there is value in this company going forward. What does that look like? Explain it to us.”
Arthur: Well, let me-- if I could-- refocus the question just slightly to match an argument that Travelers put forward. I read your request to the SEC as saying that you're not asking for the kind of standardized data that companies like Travelers and others have put out in their TCFD reports. I think Travelers tried to make an argument that your request wasn't exactly micromanagement, which would be a clear reason to turn down your request, but it was a little bit like you're asking for a specialized analysis. The Travelers seemed to be saying “we spend a lot of money on data systems and thinking about the problems in the standardized way and you're asking us to put all that aside, do it your way and then tell us what the numbers look like.” Is that a fair reading of their letter? What do you think about that argument if it is?
Danielle: No and the SEC didn't agree with that either. Truly, we've asked them to issue a report on the expected impact of climate-related pricing and coverage decisions on the sustainability of their homeowners insurance customer base. All of that information is within their control. Though they aren't currently providing that information, it's a fair thing for investors to ask what you know. You are the experts; this is your company. Tell us what your market looks like in the future under various climate scenarios.
The micromanagement argument has gotten to be so broad that companies would like to say, “we are giving you information and that's the information”. If you ask for anything different than what we're giving you, then you're micromanaging us. Of course that's not the case. Investors need information, the world changes, the information requests will be different. In this case, the insurance market, especially for homeowners has changed dramatically. Asking the company to provide this critical information is absolutely reasonable and we don't believe it's micromanaging the company.
Arthur: As part of your response just now, you noted all the different types of information that shareholders already have. You can see what's going on, you could see the data, you can see the claims rising. You know what the insurance pricing is like because it's basically a public process, at least in California. Can't you come up with the implications on your own?
Danielle: In some ways this proposal provides Travelers the opportunity to make its business case to say we that here are factors which weigh in our favor as opposed to our competitors. We haven't seen the answer that question addressed. Yes, we could guess the implications for the homeowner’s market. If you want us to just use the information that's on the table, it may not be such a good idea to invest in insurance companies. This proposal gives Travelers the opportunity to talk about why and how it believes it might have a homeowner’s market for its insurance products.
Arthur: We haven't yet addressed the issue of “subrogation”, which is a topic of high-profile litigation and an important little detour. “Subrogation” is basically a fancy way of saying let’s get the polluters to pay for the harm. Could you talk about the litigation? Could that be how Travelers is going to make this business work?
Danielle: Right. We've talked about the various things that we don't know in the absence of information, climate information, weather information, information that will help us predict the future, how is Travelers going to deal with that?
Part of the question is whether Travelers is thinking about going to the oil and gas companies and asking them to compensate the Travelers homeowners, because their alternative currently is to increase prices and now, we're starting to hit a wall where in people simply can't pay more.
Is it time for the insurance companies to go out to the oil and gas companies or other high carbon companies and say you have contributed to this problem. You've externalized massive cost to the market. We believe you're responsible in part.
What's interesting is the attribution science is pretty strong right now. You can actually go to the various oil and gas companies and say, here's your percentage of the harm that has been caused.
We think that's a market-based solution because if oil and gas companies are can no longer simply externalize the costs, then that will impact their business decisions. That's what a market does or should do. We're already seeing that. In externalizing cost of climate change, we now are in a situation where it's costing everybody more.
We think Travelers should be considering that. The State of Hawaii has said that they should be considering that. That might be something Travelers is doing, we don't know, but that's one way you they might answer this question. We might seek contributions from the companies that are creating much of the risk. That could be a solution to having to increase prices.
Arthur: Has that happened in other industries in the past?
Danielle: Yes. I understand that insurance companies looked to pharmaceutical companies in the recent crisis.
Arthur: The opioid crisis?
Danielle: Yes. They sought money from the pharmaceutical companies in the opioid crisis, and my understanding is also from the tobacco companies in paying claims related to cigarettes. The tobacco companies were contributing to the harm that that the insurance companies were paying for. So, it's not new. It has been done before. This seems an equally important time to look to that.
Arthur: Although I'm no expert, I would guess that it's going to take important expansions or extensions of the law of damages to get us there. In other words, not a “gimme”.
Danielle: It's not a gimme, but it does signal to any company that is emitting significant climate emissions or greenhouse gas emissions that they may be on the hook now, you know, sooner or even if it's later that that should be priced into what they're doing. There are almost never sure things in the courts, but there is sense there and it may make sense to explore those avenues.
Arthur: Moving on to another perspective, insurance companies have stated publicly that they hold the most comprehensive data and analysis on climate change, dating back decades and across long term timelines that enable them to forecast changing weather patterns. How does As You Sow believe that increased transparency from Travelers Insurance could benefit both customers and investors in terms of long-term stability and community well-being? Do you see increased pressure to reshape their business models to meet increasing losses from extreme changes in weather?
Danielle: I've already covered the fact that you can't look backwards. The insurance companies hold the most comprehensive data and analysis on climate change. That’s probably true. There are industry scientists that are looking at it and the dating back decades and across long term timelines. They are in a better position to forecast changing weather patterns than others, but you can't look backwards.
Whatever has happened, they will continue to need new information and certainly they know how to take information and assess risk based on that. Certainly investors agree that they are well placed to do that. That's what they do and we rely on them to do that.
Arthur: Well, do you have any concern that a report like the one you are asking for in and of itself, by clarifying the situation, would harm the company and harm its investors?
Danielle: In the short term addressing risk by putting it out into the open is part of how the market works. It's the idea that having full knowledge will help the best decisions be made. So, I don't think so.
Maybe I'll step back. When we go back to 2013, a report came out by Carbon Tracker. The report was called “The Carbon Bubble”. We read that report and we said to ourselves “almost every investor holds oil and gas”. This report says that those assets may fall in value. So, we began working with the oil and gas companies to understand whether they were addressing the risk, how they were addressing the risk.
That was the first question, because it was very clear at that point that the market was in no way valuing climate change, certainly not valuing it accurately. Over time we've had increasing information. There have been leaders in providing information and there have been laggards. The leaders haven't been harmed by being forthcoming with their investors. They're generally rewarded for that.
But more importantly, oil and gas companies were at first are saying “I don't understand the question, I don't understand what you want”. Investors were replying “we don't really know what we want, but we want you to explore what does this mean to you”. What's the risk? What are you looking at currently and what might you need to look at?
Going through that process, we had many come oil and gas companies say this has been an important process for us. This has raised, you know, red flags that we weren't aware of because they went and they looked at it much more holistically, climate risk across all their operations, looking how it impacted them not one by one, but together.
We're in that situation now with insurance companies. I think we're looking hard at these issues and providing information is going to be helpful to the market. I don't think it will hurt Travelers to actually do that analysis and provide some information to investors.
Arthur: Interesting. It begs a question for me. You talked about some companies being better, some companies being less good at doing the analysis. Historically, would you consider Travelers in terms of this analysis, their impact on climate risk to have been, relatively good or relatively behind the curve in thinking about these issues? The reason I ask, of course, is that you've focused on Travelers in this proposal. Is that because you think that they'll be responsible or is it or is it because you think they've been less responsible? Or is that not the right way to not the right question to ask?
Danielle: We have no reason to believe Travelers is better or worse at this. I guess the question is why Travelers?
Arthur: Yes. Why make this proposal at Travelers as opposed to, you know, some other insurance company, maybe one that hasn't been quite as forthcoming as Travelers has about their climate analysis. Travelers has perhaps not given you all the information you want, but maybe it has given more than others.
Danielle: I do think that Travelers has the ability to do this and they have provided some information. It made sense to say, OK, here's a question that's important to us. Some companies are still in the position of not having disclosed any information. They're farther behind in their journeys in some respects.
I hadn't thought about this necessarily, but we have been engaging with Travelers since 2022 and so they have been looking at this issue. They obviously would have been looking at it anyway. It made sense to us to ask Travelers to look in particular at these issues.
Arthur: That’s very interesting to me, and a good segue to our final question. Let’s take an even another half step back. What are the broader implications of your efforts for transparency of data used in pricing for shareholders and stakeholders alike--including policy makers, regulators and governments?
Danielle: I think the broader implications are as follows. We're asking for this information specifically because it will help investors. But the bigger crisis is at hand and it's interesting to see it happening in real time. What we see is that there still appears to be a belief that we can continue to find the money to insure greater and greater catastrophe losses. We really believe that as insurance companies, as investors and as a market, we have to step back and say, what's the reality here? The reality is already we can't afford to insure homes. It's only going to get worse.
So, let's look at the problem and not spend so much time creating what in most cases are going to be false solutions. For example, take a look at Florida's insurance market.
More and more small insurers that are undercapitalized, that are not diversified, that are in the riskiest areas are now providing a lot of insurance, which means for homeowners when the catastrophe comes, it is more than likely, not necessary but more likely, you may find yourself with a bankrupt insurer.
That's the solution? It's not a solution.
From an investor standpoint, if you're looking at long term stability of the financial system, it makes sense to address the problem. It's cheaper. It's cheaper today, it's going to be far cheaper to do it today than tomorrow, and so on.
What we're taking from this is that we really need to get to the bottom of the problem and not continue to kind of nibble around the edges because it's just getting worse.
Arthur: I’d like to take maybe a couple more minutes to ask a few miscellaneous questions? Sort of like a lightening round. OK?
Danielle: OK.
Arthur: First of all, were you surprised that the SEC gave you the ruling that you were looking for?
Danielle: It’s become very hard to predict what the SEC is doing and what the basis before its decisions are. We are still at this point trying kind of scratching our heads and saying why did this move forward and not this. I think we are waiting to see have a fuller picture of the whole season to try to understand better what's happening.
In my my vision of the world, this request was intuitive. This is an important problem. No, the issue hasn't been answered yet. So, it's not micromanagement to ask the question. It certainly should go in front of investors and companies and the issue should be aired. We think it's important. We hope that's what the SEC was thinking.
Arthur: That's a great thing to hope for. I read through the record. Most of it, not every word. There were some interesting technical arguments that I hadn't seen in most of these submissions about ownership and some of the stuff that was really in the weeds. Specifically, there was some back and forth on the evidence that you gave of shareholder ownership. There was a letter saying that you hadn't submitted the required proof of ownership. And also that your correspondence did not include sufficient documentation demonstrating that you had the legal authority to submit the proposal on behalf of the proponent.
Danielle: There are some companies that will do that. It wasn't surprising to us.
The bigger question is with the shareholder. We bring shareholder proposals using shares. So, we represent investors in our proposals. What happens is that many investors have custodians and the custodians make it very difficult.
It's a complicated process and it’s very difficult for an ordinary investor to do. It would be like filing a lawsuit. That’s why representation by organizations like ours is important. The SEC has said it's OK to be represented by people that are more expert in the process. They can handle the various things that no investor necessarily can do or maybe doesn't want to spend their time doing. but they still want to address an important issue.